Wicklow County Development Plan – First Chief Executive’s Report June 2020 Part 4.2 Submissions from Prescribed Bodies Name: Eastern and Midlands Regional Assembly A7 Issues raised The Eastern and Midland Regional Assembly notes the publication of the Issues Booklet to inform the preparation of the Wicklow County Development Plan 2021-2027 and sets out hereunder observations on behalf of the Assembly. The submission has been reviewed by the executive and approved by the members of the Eastern and Midland Regional Assembly at the meeting of 13th December 2019. Regional Spatial and Economic Strategy (RSES) The Council will be aware of the finalisation of the Regional Spatial and Economic Strategy for the Eastern and Midland Region which was made on 28th June 2019. In line with the provisions of the Planning and Development Act 2000, as amended, the Planning Authority shall ensure, when making the County Development Plan, that it is consistent with the Regional Spatial and Economic Strategy for the Eastern and Midland Region, thus ensuring full alignment between local, regional and national planning policy. In this regard, the Assembly welcomes the publication of the Issues Booklet in preparation of the new Wicklow County Development Plan. Legislative Context As required by Section 11(2) of the Planning and Development Act 2000, as amended, the Regional Assembly received notice from the Council on November 5th 2019, of its intention to review its existing County Development Plan and to prepare a new County Development Plan for its area. Under Section 27A of the Planning & Development Act, 2000 (as inserted by Section 17 of the Planning and Development Act, 2010) the Eastern and Midland Regional Assembly, is obliged to prepare submissions / observations to be submitted to the relevant Planning Authority and copied to the Office of the Planning Regulator. The submission of the Regional Assembly shall include, but shall not be limited to, recommendations regarding a number of matters including, policies or objectives of the Government in relation to national and regional population targets and the best distribution of residential development and related employment development with a view to promoting consistency with the RSES and assisting in drafting the Core Strategy; promoting regional development through maximising the potential of the region; planning for the best use of land having regard to location, scale and density of new development to benefit from investment of public funds in transport infrastructure and public transport services; and collaboration between the Planning Authority and the Regional Assembly in respect of integrated planning for transport and land use, and the promotion of sustainable transportation strategies in urban and rural areas, including the promotion of measures to reduce anthropogenic greenhouse gas emissions and address the necessity of adaptation to climate change. Accordingly, this report contains the opinion of the Eastern and Midland Regional Assembly in relation to the above matters along with recommendations as required under Section 27A of the Planning and Development Act 2000 as amended. Ensuring Consistency with the RSES – Key Areas Notwithstanding the requirement of the Planning Authority to ensure, when making the County Development Plan, that the Plan in its entirety is consistent with the Regional Spatial and Economic 81 Wicklow County Development Plan – First Chief Executive’s Report June 2020 Strategy (RSES), the following are key areas that the Assembly would like to bring attention to in order to inform the future Wicklow County Development Plan 2021-2027. Growth Strategy of the RSES: In preparing the forthcoming County Development Plan, it should be noted that Growth Enablers have been specified (Section 3.2) as part of the RSES to facilitate growth across the Region. Growth Enablers are underpinned by the spatial mapping of Functional Urban Areas (FUAs) within the Region. For the Eastern and Midland Region these are The Dublin Metropolitan Area, The Core Region and The Gateway Region. In this regard, the attention of the Council is brought to the appropriate general Growth Enablers for the Region, the Growth Enablers of the Dublin Metropolitan Area, the Core Region and Gateway Regions, which are relevant to County Wicklow. In addition, when formulating the above, the future County Development Plan shall ensure consistency with RPOs 3.2 and 3.3, aimed at securing compact growth in line with the National Planning Framework. Settlement Strategy: The RSES defines Bray and Wicklow-Rathnew as Key Towns, within the Metropolitan Area and Core Region respectively, and the Settlement Hierarchy of the County Development Plan is required to reflect this. Acknowledgement of this as part of the Issues Booklet is welcomed by the Assembly. The Issues Booklet further acknowledges the requirement of compact growth and delivering a greater proportion of development within the existing built-up area of settlements and making better use of underutilized land including infill and brownfield sites. In formulating the Core Strategy, the attention of the Council is brought to Chapter 4 of the RSES, including Settlement Strategy RPOs 4.1 and 4.2, and Appendix B of the RSES (SPA and County Population Tables), where population growth targets are to be applied in line with the requirements of the Implementation Road Map for the National Planning Framework issued under DHPLG Circular FPS04/2018. Further to the above, the Council’s attention is drawn to the transitional population projections methodology, in the NPF Implementation Roadmap and National Policy Objective (NPO) 68 of the NPF which allows for up to 20% of the phased population growth targeted in Dublin city and suburbs, to be accommodated in the wider metropolitan area i.e. outside the city and suburbs or contiguous zoned area. This is further limited to the Metropolitan Key Towns of Bray, Maynooth and Swords by the RSES. In this regard, it should be noted that the range of population projections between 84,000 and 100,500 additional people, by 2031 for Dublin City Council’s administrative as set out in Appendix B of the RSES (SPA and County Population Tables) is subject to the determination of population transfer targets under NPO 68, which will be agreed in consultation with the MASP Implementation Group, as set out in Section 5.7 of the RSES. Table 4.2 of the RSES outlines the Settlement Typologies to be included as part of the Settlement Hierarchy, which are to be defined by the County Development Plan. This includes Regional Growth Centres, Self-Sustaining Growth Towns, Self-Sustaining Towns, Towns, Villages and Rural areas. Regarding the Key Towns of Bray and Wicklow-Rathnew, RPO 4.26 addresses the role of Key Towns within Core Strategies and this is augmented by RPOs 4.37-4.41 and 4.54-4.58 which relate to Bray and Wicklow-Rathnew respectively. Table 4.3 of the RSES provides further guidance and details policy responses for the different settlement typologies. Future County Development Plan policy should ensure consistency in this regard. 82 Wicklow County Development Plan – First Chief Executive’s Report June 2020 Bray, Maynooth and Swords are the Key Towns identified within the Metropolitan Area Strategic Plan (MASP) which sets out an integrated land use and transportation strategy for the sequential development of the Dublin Metropolitan Area. Bray, along with Greystones are located along the MASP’s North-South Strategic Development Corridor and Table 5.1 identifies strategic residential, employment and regeneration development opportunities, capacity infrastructure and phasing to achieve compact growth in tandem with the delivery of key public transport projects as set out in the National Development Plan. In addition, Section 5.7 of the MASP and RPOs 5.4 and 5.5 are relevant with respect to Bray as a Key Town within the Metropolitan Area and future county development plan policy should be consistent with this approach. Section 3.1 and Appendix A of the RSES provide detail on the Asset-Based Approach to spatial development and it is considered that the Planning Authority will find this useful in formulating a Settlement Strategy for the County Development Plan that secures the proper planning and sustainable development of the area. Issues Booklet The Regional Assembly welcomes the explicit recognition, contained as part of the Issues Booklet, of the policy hierarchy with which the Wicklow County Development Plan is required to be consistent with, including reference to the RSES and NPF. In addition, the broad areas outlined including the Core Strategy and Settlement Hierarchy, Climate Change, Flooding and Coastal Zone Management, Housing, Economic Development and Employment, Town and Village Centres and Retail, Tourism and Recreation, Heritage, Community Development, Transportation and Infrastructure, Town and Village Plans, and Environmental Assessments, are considered to provide a robust basis for scoping out and developing the overall strategy. This submission has detailed each of these sections below and consideration should be given to the following in order to ensure consistency with the RSES when formulating the County Development Plan. The Vision: While not set out within the Issues Booklet it is anticipated that a Vision for the County will be set out in the new Wicklow County Development Plan 2021-2027. In determining the overall vision of the Plan, it is recommended that the Council consider the Vision, Key Principles and Regional Strategic Outcomes (RSOs) of the RSES (Chapter 2) in crafting this. The RSOs are aligned to the National Strategic Outcomes (NSOs) of Project Ireland 2040 and it should be noted that the ability to demonstrate delivery of these may potentially be linked to future funding sources. Core Strategy and Settlement Hierarchy: The Issues Booklet recognises that the Core Strategy must demonstrate that the development plan is consistent with National and Regional Policy such as the NPF and RSES. In doing so, the Core Strategy must include a new settlement hierarchy reflecting the spatial framework set out in the RSES.